Quebec Law 25: What Your Organization Needs to Know and Implement

A Law That Is Transforming Business Practices

Law 25 does far more than simply update the legal framework. It fundamentally reshapes the way organizations collect, use, and protect personal information. Its impact extends directly to digital tools, marketing practices, communications, and internal processes.

For many organizations, this means reassessing, and in some cases redesigning, practices that may have been tolerated during the transition period but no longer meet today’s compliance requirements.

A Broader Reach Beyond Quebec

Law 25 applies to any organization that handles the personal information of Quebec residents, including organizations that do not have a physical presence in the province.

This broad scope means that businesses located outside Quebec, and even outside Canada, may still be subject to the law when they interact with the Quebec market and collect personal information from Quebec residents. In other words, an organization’s physical location does not necessarily determine whether Law 25 applies.

In today’s digital environment, where geographic boundaries are increasingly blurred, this is especially important. A website accessible to users in Quebec, a marketing campaign targeting Quebec residents, or a database containing their personal information may be enough to bring an organization within the scope of the law.

Ultimately, this approach is intended to provide Quebec residents with a strong and consistent level of privacy protection, regardless of where the organizations they interact with are located.

A Major Shift in Data Governance

Law 25 marks a significant shift in how organizations are expected to manage and protect personal information. It is no longer enough to simply adopt practices that comply with the legislative framework; organizations must also be able to demonstrate that they are actively safeguarding the personal information entrusted to them.

This requires greater transparency around how personal information is collected, used, and shared. Individuals should be able to clearly understand how their information is being handled, for what purposes, and under what circumstances. Transparency therefore becomes a key element in building and maintaining trust.

The law also places greater responsibility on organizations. In cases of non-compliance, the consequences can be significant, both financially and reputationally.

Compliance is therefore no longer solely a legal matter. It has become a strategic business consideration that affects the organization as a whole.

An Opportunity to Strengthen and Differentiate Your Organization

Although Law 25 is often viewed as a constraint, it can also create opportunities for organizations that take a proactive approach to compliance.

By clarifying their practices and implementing strong data governance measures, organizations can improve consistency, strengthen client relationships, and foster greater transparency and trust.

This can also enhance the organization’s reputation with clients and regulatory authorities.

As individuals become increasingly concerned about privacy, a proactive approach to compliance can provide a meaningful competitive advantage. It helps position an organization as responsible, credible, and aligned with current market expectations.

More broadly, compliance has become an important, and often essential, consideration in many business processes, particularly partnerships and requests for proposals. Strong compliance practices can therefore directly support an organization’s growth, credibility, and long-term sustainability.

Organizational Compliance: Where to Start

For organizations looking to close compliance gaps or strengthen their existing policies, practices, and controls, several practical steps can be taken to build a solid foundation.

These recommendations apply not only to Law 25, but also to other privacy and compliance frameworks.

• Identify the legal and regulatory obligations that apply to your organization based on your activities, tools, and the types of personal information you collect and process.

• Assess your current practices, particularly how personal information is collected, stored, used, and, where applicable, shared.

• Review or develop your privacy policies and consent mechanisms to ensure they are clear, accessible, and compliant with applicable legislation.

• Put appropriate controls in place for your digital tools, including your website, platforms, and marketing campaigns, to ensure personal information is handled appropriately.

• Establish clear internal guidelines outlining your organization’s compliance obligations and make them easily accessible to employees.

• Educate your teams on privacy best practices and provide regular reminders about their role in protecting personal information.

• Implement ongoing monitoring and review processes to help maintain compliance over time.

Need More Clarity?

Compliance with Law 25 can be complex, and organizations often have questions about their obligations, tools, and existing practices.

Whether you need to assess your current position, strengthen your compliance approach, or receive support throughout the process, our team can guide you through each step.

If you have questions or need support, please do not hesitate to contact us.

Frequently Asked Questions

Who must comply with Quebec’s Law 25?

Any organization that handles the personal information of Quebec residents may be subject to Law 25, regardless of where it is located. This includes businesses based in Ontario, France, the United States, or elsewhere if they collect or process personal information belonging to Quebec residents.

A website accessible from Quebec, a marketing campaign targeting Quebec users, or a database containing their personal information may be enough to bring an organization within the scope of the law.

What penalties can apply under Law 25?

Penalties can be significant and may be calculated based on an organization’s worldwide turnover. The law also provides for punitive damages in certain circumstances.

The exact amounts, thresholds, and conditions of application should be confirmed with Quebec’s Commission d’accès à l’information, the authority responsible for overseeing the legislation.

Is a Privacy Officer required?

Yes. Every organization must designate a person responsible for the protection of personal information, and that person’s title and contact information must be published on the organization’s website.

By default, this responsibility falls to the individual with the highest level of authority within the organization, although it may be delegated in writing.

What should an organization do in the event of a privacy incident?

The organization must take appropriate steps to reduce the risk of harm, maintain a record of privacy incidents, and notify the Commission d’accès à l’information and affected individuals when an incident presents a risk of serious harm.

Where should an organization start when working toward Law 25 compliance?

Start with an assessment of your current data practices: what personal information you collect, where it is stored, how it is used, who has access to it, and with whom it is shared.

Without this clear picture, it is difficult to develop appropriate privacy policies, consent mechanisms, and compliance controls.